Income Tax : This document provides a complete reference on compounding of offences, including application procedures, offence-wise charges, re...
Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...
Income Tax : The FAQs explain the prosecution provisions under the Income-tax Act, covering offences such as tax evasion, non-payment of TDS/TC...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : Courts are divided on whether the DRP-specific deadline under Section 144C(13) overrides the general assessment time bar in Sectio...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : ITAT Delhi quashed a Section 153C assessment, holding that a consolidated and defective satisfaction note invalidated jurisdiction...
Income Tax : ITAT held that a registered sale deed without corroborative evidence is not incriminating material and cannot support additions in...
Income Tax : ITAT held reassessment under Sections 147/148 invalid because it was based on a pre-1 April 2021 third-party search, requiring pro...
Income Tax : ITAT Mumbai quashed a Section 148 notice issued after the limitation under the first proviso to Section 149, holding the reassessm...
Income Tax : ITAT held that penalty under Section 271D cannot survive where the Assessing Officer failed to record satisfaction in the assessme...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
The Tribunal rejected estimated additions based on alleged circular trading due to lack of seized material or cash trail. The key takeaway is that suspicion and presumptions cannot replace evidence in search assessments.
The Tribunal found that CIT(A) erred by linking the protective addition to another company. The assessment was remanded for correct identification of the beneficiary.
The ruling highlights that immunity under DTDRS is general to penalty proceedings. Consequently, revising penalties merely because a different section might apply is impermissible.
The Revenue sought to reopen completed assessments under section 153A without fresh incriminating evidence. The Tribunal ruled that such additions are barred, following Kabul Chawla and Abhisar Buildwell.
The Tribunal ruled that the reassessment was time-barred because limitation was wrongly computed from the search date. The key takeaway is that receipt of seized material governs jurisdiction for non-searched persons.
Madras High Court held that Settlement Commission doesn’t possess power to change the head of income and convert the undisclosed portion of income into income u/s. 699B. Further, Settlement application is bound to be rejected once Settlement Commission arrives at the conclusion that full and true disclosure is not done.
The issue was whether revision under section 263 could survive when no incriminating material was found for an unabated year. The tribunal held that without search-based evidence, the completed assessment could not be disturbed.
ITAT Pune held that disallowance of interest paid on housing loan is upheld since assessee has failed to provide documentary evidence like loan sanction letter or bank certificate. Accordingly, ground raised by assessee is dismissed.
The issue was whether LTCG could be taxed in a search assessment without incriminating evidence for the year. The Tribunal held that, absent such material, additions under section 153A are unsustainable.
The issue was whether cash found at a third party’s premises could be added in the assessee’s 153A assessment. The Tribunal held such additions invalid, ruling that proceedings must be initiated under section 153C.
